## Facts

- Reiyn Keohane, a transgender woman incarcerated in a Florida men’s prison, was diagnosed with gender dysphoria and had transitioned socially and medically before incarceration.
- Florida prison officials initially limited gender-dysphoria treatment under a “freeze-frame” policy tied to treatment at intake; officials later provided hormone therapy and additional measures (counseling, private showers, and use of female pronouns).
- Keohane sought further accommodations to socially transition in prison (including longer hair and access to female undergarments and grooming items), which officials denied based on grooming rules and asserted security concerns.
- Keohane experienced severe distress, including self-harm, suicide attempts, and an attempted self-castration.
- Keohane’s expert testified that social transition was medically necessary for her treatment; prison providers and an opposing expert disagreed and maintained that existing measures were adequate.
- The prison system repealed the freeze-frame policy and continued providing hormone therapy by the time of appeal.
- After a bench trial, the district court found deliberate indifference under the Eighth Amendment and issued injunctive relief requiring continued hormone therapy and permission for social-transition measures.

## Issues

1. Whether claims challenging the former freeze-frame policy and the earlier denial of hormone therapy became moot after the policy change and provision of hormones.
2. Whether refusal to permit requested social-transition accommodations constituted deliberate indifference to a serious medical need under the Eighth Amendment.

## Decision

- The court held the challenges to the rescinded freeze-frame policy and initial hormone-therapy denial were moot because the challenged practices ceased and there was no reasonable expectation they would recur as applied to Keohane.
- On the merits, the court held that denying the requested social-transition accommodations did not violate the Eighth Amendment.
- The court concluded prison officials had provided a meaningful course of treatment (including hormones and related care) and that disagreements among medical professionals about medical necessity did not establish deliberate indifference.
- The court gave substantial deference to prison officials’ security and management judgments in the all-male facility.
- Disposition: the court vacated the injunction, dismissed the moot portions, and reversed the remainder relating to compelled social-transition accommodations.

## Legal Principles

- Article III requires a live controversy; when challenged policies are repealed and the complained-of treatment is provided, claims for prospective relief may become moot absent a reasonable likelihood of recurrence.
- Eighth Amendment medical-care claims require (1) an objectively serious medical need and (2) subjective deliberate indifference—more than negligence—shown by conscious disregard of a substantial risk of serious harm.
- A difference of medical opinion about appropriate treatment generally does not establish deliberate indifference when officials provide some meaningful treatment.
- Courts owe substantial deference to prison administrators’ security and operational judgments when assessing requested accommodations within a correctional facility.

## Conclusion

The Eleventh Circuit dismissed as moot the claims tied to the rescinded intake-based policy and past hormone denial, and held that the continued refusal to allow social-transition accommodations did not amount to deliberate indifference where officials provided ongoing hormones and related care and articulated security-based reasons for denying additional measures.


Keohane v. Fla. Dep’t of Corr. Sec’y, 952 F.3d 1257 (11th Cir. 2020)